Much of the paperwork in this case has been designated as confidential, but it looks like the IRS first issued its demand in May 2016. Since then, the talks have centered on how the IRS is calculating Houston’s unpaid royalty amount.

The IRS has calculated more than $22 million in untaxed royalties. On the other hand, Houston estate attorneys say the number is closer to $2 million. This wide gap in numbers is similar to what attorneys are going through in the estate of Michael Jackson.

Some of the heft in the IRS’s calculation is based on Whitney’s “image and likeness.” This is a relatively intangible asset that can generate a massive amount of revenue after a star has passed away. There’s no justification for exactly how the IRS arrived at an $11.7 million “image and likeness” figure. It’s really anyone’s guess.

The IRS says that, of the $22 million-plus demand, the Whitney Houston Estate has been hit with $11 million in taxes, which will apparently include some substantial late fees when everything is said and done and all the issues are resolved.

Some question how Houston’s attorneys can lower the payments. Other insiders believe that the matter is close to resolution, with both sides “nearing a deal.”

The US Tax Court has stipulated that the next status filing is due December 7.